Corrective Action Plans

Finding 1160397 (2025-001)

Material Weakness 2025

TX

Student Financial Aid Special Tests & Provisions Reporting

Finding 2025-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.268 Finding Summary: For a small group of students with very specific circumstances, our software’s enrollment report autopopulated an effective date of enrollment change tha...

Finding 2025-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster ALN: 84.268 Finding Summary: For a small group of students with very specific circumstances, our software’s enrollment report autopopulated an effective date of enrollment change that did not match the actual effective date. UMHB did not realize that these specific circumstances would require manual processes to identify and correct the enrollment report prior to submission. As a result, four students had incorrect status change effective dates reported to NSLDS. Responsible Individuals: Trent Bridges, Director Data Quality and Institutional Analytics Corrective Action Plan: UMHB plans to implement the following: 1. Review all the coding on system reports used for NSLDS reporting to assess accuracy and completeness of the data based on any changes in business practice and make updates to system reports as necessary. 2. Update internal process to document any required special handling of records based on system limitations. 3. Reassess system report and processes used for NSLDS reporting prior to the beginning of each fall and spring semester. Anticipated Completion Date: Fall 2025

View Audit 370810

Finding 1160317 (2025-002)

Material Weakness 2025

Oklahoma Christian University and Subsidiaries

OK

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions

Student Financial Assistance Cluster Assistance Listing Number 84.268 Federal Direct Student Loans, and 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2024-2025 Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – 34 CFR Sections 690.8...

Student Financial Assistance Cluster Assistance Listing Number 84.268 Federal Direct Student Loans, and 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2024-2025 Criteria or Specific Requirement – Special Tests and Provisions – Enrollment Reporting – 34 CFR Sections 690.83(b)(2) and 685.309 Condition – Student enrollment and program information was not communicated to the National Student Loan Data System (NSLDS) timely or accurately Questioned Costs – N/A Context – A total of 7 out of 40 students tested were noted to have at least 1 error in enrollment or program information reported to NSLDS within the required 60 days. Our sample was not, and was not intended to be, statistically valid. Effect – NSLDS was not notified of student status changes or program information in accordance with compliance requirements. Cause – The University did not have effective internal control processes in place to ensure the accurate collection, review, and reporting of student status changes occurred timely or accurately. The recent turnover in personnel resulted in a lack of oversight as well. Indication as a Repeat Finding – Yes Recommendation – The University should review its internal controls surrounding the enrollment reporting process and ensure internal controls provide for the timely and accurate reporting of student status changes. Views of Responsible Officials and Planned Corrective Actions – Tina Petersen, Registrar, will oversee the two-fold corrective action plan. First, we are immediately reviewing our degree posting policy and dates to create a more effective and standardized process. This policy review will enable us to properly assess any delayed completers and ensure that students are "completed" in our systems and reported to NSLDS in a more timely and accurate manner. Additionally, we are updating our formal, step-by-step written procedure manual for all enrollment reporting processes, with a specific focus on degree conferral and the subsequent reporting to NSLDS. This updated manual will serve as a crucial resource to ensure procedural consistency, especially during personnel changes. Second, we are enhancing our training protocols and internal controls. All staff members involved in the NSLDS reporting process will be required to attend mandatory, recurring training to ensure they are up-to-date on all compliance requirements. We will also implement a more robust system of checks and balances to verify the accuracy of the data before it is submitted to NSLDS. By taking these steps, the University is dedicated to improving its internal controls and fully remediating this finding. The corrective action plan will be implemented by November 1, 2025. Office of Financial Services PO Box 11000 Oklahoma City, OK 73136 405.425.5190 financialservices@oc.edu

View Audit 370701

Finding 1160316 (2025-001)

Material Weakness 2025

Oklahoma Christian University and Subsidiaries

OK

Student Financial Aid Subrecipient Monitoring Matching / Level of Effort / Earmarking

Student Financial Assistance Cluster Assistance Listing Number 84.268 Federal Direct Student Loans, and 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2024-2025 Criteria or Specific Requirement – Disbursements to or on behalf of students, 34 CFR Section 668.164(h)(2) Con...

Student Financial Assistance Cluster Assistance Listing Number 84.268 Federal Direct Student Loans, and 84.063 Federal Pell Grant Program U.S. Department of Education Program Year 2024-2025 Criteria or Specific Requirement – Disbursements to or on behalf of students, 34 CFR Section 668.164(h)(2) Condition – Students did not receive refunds within the required timeframe Questioned Costs – N/A Context – 7 out of 25 students tested received their credit balance refund more than 14 days after the credit balance was generated. All but 1 of these students received their refund within 16 days of the generation of the credit balance. Our sample was not, and was not intended to be, statistically valid. Effect – Noncompliance with federal regulations requiring timely disbursement of credit balance refunds Cause – Due to the high volume of credit balance refunds being processed, the University encountered operational constraints that prevented all refunds from being generated within the designated 14-day timeframe. Indication as a Repeat Finding – N/A Recommendation – To ensure timely refund of student credit balances, implement a control that flags any refund not processed before the end of the 14-day timeframe for immediate review and escalation. Additionally, establish a monitoring report to track refund timeliness weekly and reinforce accountability for processing within the required timeframe. Views of Responsible Officials and Planned Corrective Actions – Amy Schlup, Director of Student Financial Services, and Carrie Hamilton, Assistant Director of Financial Aid, will oversee the corrective action plan. As part of this process, they will review the daily Student Refund Report to identify and assist the personal financial counselor in expediting student refunds. The Student Financial Services team will also review and retrain on the proper procedures for processing refunds within the required timeframe. The corrective action plan is already in progress and will be fully implemented by October 1, 2025. Office of Financial Services PO Box 11000 Oklahoma City, OK 73136 405.425.5190 financialservices@oc.edu

View Audit 370701

Finding 1160270 (2025-001)

Material Weakness 2025

The Episcopal Theological Seminary of the Southwest

TX

Questioned Costs Student Financial Aid Eligibility

Corrective Action Plan (CAP for Finding 2025-001) Date: 2 October 2025 Responsible official: Frederick L. Clement, Executive Vice President Management has corrected the finding by taking the following action: First, the institution entered into a professional services agreement with Higher Education...

Corrective Action Plan (CAP for Finding 2025-001) Date: 2 October 2025 Responsible official: Frederick L. Clement, Executive Vice President Management has corrected the finding by taking the following action: First, the institution entered into a professional services agreement with Higher Education Assistance Group to provide a comprehensive business process review of its financial aid operations. The objective of this review is to improve upon the functionality of processes, internal controls, and systems to ensure regulatory compliance and the effectiveness of service deliverables to students receiving financial aid. This review will include updates to policies, procedures, and internal controls for the import and export of electronic records, document tracking and file review, packaging and awarding, satisfactory academic progress, disbursement and reconciliation, withdrawal and Return to Title IV. Workflow and gap analysis will be performed to ensure intraoffice Title IV program compliance and best practices. Second, the institution has entered into a professional services agreement with Higher Education Assistance Group to provide interim staffing and third-party federal student aid processing including, but not limited to, counseling students and families on financial aid options, assisting with the management of Federal Direct Loan and Federal Graduate PLUS Loan programs to include student eligibility, file review, awarding, and origination and disbursement authorization using Populi, COD and other Department of Education software. In addition, Higher Education Assistance Group will provide additional Title IV training for personnel involved in federal student aid processing. With more than 35 years of experience, Higher Education Assistance Group and its team of seasoned consultants, all of whom have worked in federal student aid administration, whether in public/private colleges and universities or for the Department of Education itself, specializes in the compliant administration of Title IV student financial aid programs. The institution will adopt a supplemental internal control to cross-check student eligibility for Direct PLUS loans to ensure that an over-award is not originated and disbursed. Anticipated completion date: November 15, 2025

View Audit 370654 Questioned Costs: $1

Finding 1160239 (2025-002)

Material Weakness 2025

Northwest University

WA

Student Financial Aid Reporting Significant Deficiency

Auditors noted that for two of the six sampled students, funds were returned to ED more than 45 days after the date the University determined the student had withdrawn. For one selection, a Return of Title IV calculation was performed timely, but an administrative error caused the disbursement to be...

Auditors noted that for two of the six sampled students, funds were returned to ED more than 45 days after the date the University determined the student had withdrawn. For one selection, a Return of Title IV calculation was performed timely, but an administrative error caused the disbursement to be delayed eight months. For the second selection, the University was notified of withdrawal in early March 2025 and student was included in registrar’s withdrawal listing, but was missed in review by Student Financial Services until late April 2025. Contact Person(s): Vickie Rekov, VP Enrollment Services; Roger Wilson, Associate Director of Financial Aid, SFS; Ryan Porter, CFO and Bernie Rundquist, Controller Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: All employees in Student Financial Services and Accounting Office involved in the reporting, distribution, drawdown and return of federal funds have reviewed the criteria under 34 CFR 668.22 The two departments involved will be meeting in the month of September 2025 to review policies and procedures to ensure controls exist and are well documented to ensure funds are returned timely. In-charge personnel will gather training resources to educate those involved in the reporting, disbursement and return of Title IV Funds. Anticipated completion date: October 2025

View Audit 370626

Finding 1159711 (2025-001)

Material Weakness 2025

Chapman University and Affiliates

CA

Student Financial Aid Reporting

The Office of the University Registrar and the Office of the Law Registrar have reviewed current policies and procedures related to the reporting of status changes in NSLDS. The Office of the Law Registrar will report status changes to National Student Clearinghouse no later than 30 days after degre...

The Office of the University Registrar and the Office of the Law Registrar have reviewed current policies and procedures related to the reporting of status changes in NSLDS. The Office of the Law Registrar will report status changes to National Student Clearinghouse no later than 30 days after degree conferral but no later than June 30. In additional they will follow up with NSC three business days after submission to verify that the file was received and processed correctly. The Law School does not confer degrees year-round. Based on the ABA accreditation and program plan, Fowler School of Law has three conferral dates: January 31, June 10, and September 1. Most students are conferred on June 10. The Office of the University Registrar will report enrollment status changes to the National Student Clearinghouse every 30 days. Unlike the Law school, the University Registrar’s office confers degree year-round. The registrar’s office is scheduled to submit a Degree Verify file every two weeks to the clearinghouse and will review students in submited degree file for accuracy in our reporting.

View Audit 370308

Finding 1159573 (2025-001)

Material Weakness 2025

Baylor University

TX

Student Financial Aid Reporting Subrecipient Monitoring

Federal and State Financial Assistance Programs Year Ended May 31, 2025 CORRECTIVE ACTION PLAN Audit Finding Reference: 2025-001 Planned Corrective Action: The University conducted a full review of the population of cancellations for the fiscal year ending May 31, 2025, comprising of 53 students. Th...

Federal and State Financial Assistance Programs Year Ended May 31, 2025 CORRECTIVE ACTION PLAN Audit Finding Reference: 2025-001 Planned Corrective Action: The University conducted a full review of the population of cancellations for the fiscal year ending May 31, 2025, comprising of 53 students. The review identified seven instances of late reporting, all of which were previously corrected through the University’s monthly disbursement reconciliation processes, but beyond the 15 calendar day reporting requirement. Each of the identified instances resulted from a system defect which caused canceled BBAY Direct Loans reduced to zero (“0”) to receive an automatic null attendance cost. Due to the automatic null value, the record was excluded from the financial aid management system to COD record extraction process. The University has created a report to identify instances where the attendance cost value is null. When identified, action will be taken to populate the attendance cost to zero and allow extraction. The records will be subsequently verified to confirm extraction for submission to COD and reports will be reviewed weekly by the supervisor. The University will continue to review and implement additional controls to ensure disbursement records are submitted to COD within 15 calendar days. To ensure enhanced oversight and monitoring controls are effective to maintain compliance and timely reporting to COD, management will incorporate this review into their routine Assurance validation processes for students from the identified population. These remediation efforts and risk management strategies will continue to be reviewed and implemented throughout fiscal year 2026. The University continues to update controls as needed to ensure compliance with an estimated completion date of May 31, 2026. Contact Person: Suzanne Weems Controller Baylor University Phone: (254) 710-3731

View Audit 370219

Finding 1153477 (2025-002)

Material Weakness 2025

The Corporation of Gonzaga University

WA

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

FINDING 2025‐002 – Special Tests and Provisions – Return of Title IV (R2T4) Funds Significant Deficiency in Return of Title IV Funds Processing Recommendation: The University should enhance its monitoring and review procedures to ensure that all unofficial withdrawals are identified and reported wit...

FINDING 2025‐002 – Special Tests and Provisions – Return of Title IV (R2T4) Funds Significant Deficiency in Return of Title IV Funds Processing Recommendation: The University should enhance its monitoring and review procedures to ensure that all unofficial withdrawals are identified and reported within the federally required timeframe. Strengthening this process will support the timeliness of federal compliance. Response: There is no disagreement with this audit finding. Action taken in response to finding: Some of the corrective actions noted in our response to finding 2025-001 also apply here. For example, quality assurance reports to identify students who withdraw from all classes in a part of term and the upcoming joint training and process mapping session with Student Financial Services and the Registrar’s Office will strengthen understanding of how enrollment status updates drive downstream compliance, including R2T4 processing. These steps will also ensure exceptions are addressed consistently and that communication channels between offices are clear. To address immediate gaps specific to R2T4 compliance, the Registrar’s Office has enhanced training regarding R2T4 compliance requirements related to recording withdrawals and enrollment changes in a timely, accurate and consistent manner. Additional quality checks are being implemented to confirm that withdrawal dates and status changes are entered accurately into the student information system so that R2T4 calculations are completed within federal timeframes. Together, these interventions are designed to ensure the timeliness and accuracy of R2T4 processing and compliance with federal requirements. We expect to have these corrective actions completed by September 12, 2025. Contact Person(s): Sarah Everitt, Dean of Student Financial Services; Maxwell Kwenda, University Registrar & Director of Institutional Research

View Audit 366726

Finding 1153470 (2025-001)

Material Weakness 2025

The Corporation of Gonzaga University

WA

Student Financial Aid Special Tests & Provisions Reporting

FINDING 2025‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Recommendation: The University should implement a reconciliation between the system of record and the reporting system to ensure all student changes (enrollment status an...

FINDING 2025‐001 – Special Tests and Provisions – Enrollment Reporting Significant Deficiency in Internal Control over Compliance Recommendation: The University should implement a reconciliation between the system of record and the reporting system to ensure all student changes (enrollment status and address changes) are reported on a timely basis. Response: There is no disagreement with this audit finding. Action taken in response to finding: Gonzaga has already taken action and implemented quality assurance reports and monitoring to ensure all student changes (enrollment status and address changes) are reported timely. Additionally, to strengthen compliance going forward, Student Financial Services and the Registrar’s Office are partnering to conduct a joint annual training and process mapping session for key personnel. This session will provide an overview of enrollment reporting requirements, outline the steps needed when exceptions to normal policies occur, and evaluate processes to improve understanding of how decisions affect both upstream and downstream functions. The session will also focus on building a shared understanding of reporting processes, identifying gaps in procedures and knowledge, and establishing communication channels so that exceptions are addressed timely, consistently and appropriately. These actions are designed to enhance internal controls and ensure compliance of timely reporting between the system of record and the reporting system, and we expect to complete this training by September 12, 2025. Contact Person(s): Sarah Everitt, Dean of Student Financial Services; Maxwell Kwenda, University Registrar & Director of Institutional Research

View Audit 366726

Finding 575411 (2025-002)

Significant Deficiency 2025

Andrews University

MI

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Views of Responsible Officials and Planned Corrective Actions – To address the identified issues related to student withdrawal processing and Return to Title IV (R2T4) calculations, the University will implement the following steps: 1. Process Review and Collaboration: A joint meeting will be held w...

Views of Responsible Officials and Planned Corrective Actions – To address the identified issues related to student withdrawal processing and Return to Title IV (R2T4) calculations, the University will implement the following steps: 1. Process Review and Collaboration: A joint meeting will be held with key personnel from Academic Records and Financial Aid to review current withdrawal procedures, including the use of drop and exit forms. Emphasis will be placed on ensuring that appropriate withdrawal codes are consistently applied to support accurate and automated R2T4 processing. The goal is to establish a unified and clearly documented process that meets the operational needs of both departments. 2. Systematic Scheduling and Monitoring: Withdrawal-related tasks, including the running of BANNER return reports and other custom reports developed by the IT team, will be scheduled at regular intervals to ensure timely identification and processing of student withdrawals. These tasks will be integrated into departmental calendars, with scheduled dates already entered for the Fall 2025 and Spring 2026 semesters. 3. Ongoing Oversight and Communication: A communication protocol will be developed to ensure that all relevant documentation, including drop forms, is consistently shared between departments. This will help prevent delays in processing and ensure compliance with federal financial aid regulations.

View Audit 365458

Finding 575409 (2025-001)

Significant Deficiency 2025

Andrews University

MI

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Views of Responsible Officials and Planned Corrective Actions – The National Student Clearinghouse (NSC) Graduation and Enrollment Change Status’ submission calendar will be updated to reflect the necessary reporting timeline. The report will be completed after verification of graduation requirement...

Views of Responsible Officials and Planned Corrective Actions – The National Student Clearinghouse (NSC) Graduation and Enrollment Change Status’ submission calendar will be updated to reflect the necessary reporting timeline. The report will be completed after verification of graduation requirements and credentialing are completed by the Academic Record’s Department. Additional training will be provided to all members within the department to ensure timely submissions.

View Audit 365458

Finding 572429 (2025-001)

Significant Deficiency 2025

Regis University

CO

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Finding 2025-001 Personnel Responsible for Corrective Action: Deborah Vinnola, Registrar Anticipated Completion Date: September 30, 2025 Corrective Action Plan: The Office of the Registrar has put into place a more detailed corrective action plan regarding the finding of delayed enrollment and non...

Finding 2025-001 Personnel Responsible for Corrective Action: Deborah Vinnola, Registrar Anticipated Completion Date: September 30, 2025 Corrective Action Plan: The Office of the Registrar has put into place a more detailed corrective action plan regarding the finding of delayed enrollment and non-enrollment reporting to NSLDS through NSC. The Office of the Registrar has adjusted the Degree Verify submission from every 45 days to every 30 days to NSC to ensure graduation dates are reported in a more timely fashion for NSLDS within the required 60 days for financial aid. Starting Summer 2025, the Office of the Registrar has begun inactivating academic programs for students who have not had registration activity within the last two to three academic years to ensure that they are not reported as enrolled to NSC/NSLDS. NSC Enrollment Reporting will continue to be submitted every 30 days and the Office of the Registrar has worked to review the reporting criteria using terms and not semesters to better report active enrollment in current courses. The Ellucian Graduation Application form and process is in the final stages of testing which will eliminate completely the need to add a pseudo course with a future date after the student’s current program has been inactivated or graduated. The Office of the Registrar will be more proactive with the colleges for identifying students who have not graduated within the six year (undergraduate), four year (graduate) and certificate time frames by working with the appropriate dean’s offices. This should eliminate those students who have completed their coursework; close to completing their coursework but were never reviewed by their advisor/program for graduation. Since Regis uses the end date of the last course completed, the Office of the Registrar will work with advising units to review the lists to increase a better reporting of degree completion.

View Audit 363564

Finding 570847 (2025-001)

Significant Deficiency 2025

Cornish College of the Arts and Cornish Foundation

WA

Student Financial Aid Reporting Significant Deficiency

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: Th...

Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the College review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The student that was incorrectly coded as FWS funds, the funds were immediately reclassified as institutional aid. Since Cornish, did not draw down all FWS funding, it did not impact the G5 drawdown and no needs needed to be returned. Going forward, a higher-level review will be conducted for students with high SAI and low need to ensure that no need-based funds, if not eligible, are in the packaging. This review, will take place after the initial counselor review, but before a student can begin working in the FWS program. This third check will ensure that these types of files are again reviewed in a timely manner and no over awards will happen in the future. Name(s) of the contact person(s) responsible for corrective action: Sara Drummond Planned completion date for corrective action plan: June 16th, 2025

View Audit 361771

Finding 1216383 (2024-003)

Material Weakness 2024

County of Carbon

PA

Student Financial Aid Subrecipient Monitoring Reporting

Federal Program: Assistance Listing #'s 93. 778, Medical Assistance Program, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: 13-1415MATP-4-2; 93.658, Foster Care Title IV-E, Passed Through Pennsylvania Department of Human Services, PassThrough Entit...

Federal Program: Assistance Listing #'s 93. 778, Medical Assistance Program, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: 13-1415MATP-4-2; 93.658, Foster Care Title IV-E, Passed Through Pennsylvania Department of Human Services, PassThrough Entity Identifying Number: not available; 14.228, Community Development Block Grants, Passed Through Pennsylvania Department of Community and Economic Development, U.S. Department of Housing and Urban Development; 93.558, Pass-Through Granter #'s C000073823, C000075969, C000082698, C000086225, and C000088719, Temporary Assistance for Needy Families, Passed Through Pennsylvania Department of Labor and Industry, Pass-Through Entity Identifying Number: not available, 21.023, Emergency Rental Assistance Program, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available. Prior Year Finding Number: 2023-005 Criteria: Pursuant to the provisions of the Uniform Guidance, under Section 200.512(a), the County is required to complete and submit its Single Audit and related Data Collection Form within nine months of the end of its fiscal period (September 30) of the following year. Condition/Context The County's Single Audit and reporting package was delayed for the year ended December 31, 2023 beyond the nine-month due date. Effect: The County is not in compliance with certain requirements of the Uniform Guidance, including the Single Audit reporting requirements. Questioned Costs: None. Cause: Reconciliations and reports were not completed on a timely basis, and therefore, the completion and filing of its December 31, 2023 Single Audit and reporting package was not prioritized. Recommendation: We recommend that County management review its staffing and personnel responsibilities to prioritize the completion of its audit responsibilities within the prescribed timeframes. Views of Responsible Officials and Planned Corrective Actions: The County plans to have information ready for the auditors to get 2024 done in a reasonable time frame. Between staffing and priorities, the County hopes to have cleared by the 2025 audit.

View Audit 402918

Finding 1216232 (2024-009)

Material Weakness 2024

Barclay College

KS

Student Financial Aid

Return of Title IV (R2T4) Unearned Funds Planned Corrective Action: A process will be implemented to run a 0-credit report at the end of each semester. This will ensure withdrawals are followed up on and that R2T4s are completed in a timely manner, if required. A process will be implanted to track s...

Return of Title IV (R2T4) Unearned Funds Planned Corrective Action: A process will be implemented to run a 0-credit report at the end of each semester. This will ensure withdrawals are followed up on and that R2T4s are completed in a timely manner, if required. A process will be implanted to track student attendance in classes. Person Responsible for Corrective Action Plan: Lori Larsh, Vice President for Business Services Anticipated Date of Completion: 07/31/2026

View Audit 402736

Finding 1216230 (2024-008)

Material Weakness 2024

Barclay College

KS

Student Financial Aid Reporting Subrecipient Monitoring

Common Origination and Disbursement (COD) Reporting and Reconciliations Planned Corrective Action: Procedures will be implemented to monthly reconcile FDL and Pell disbursements to student accounts with disbursements reported to COD. Person Responsible for Corrective Action Plan: Lori Larsh, Vice Pr...

Common Origination and Disbursement (COD) Reporting and Reconciliations Planned Corrective Action: Procedures will be implemented to monthly reconcile FDL and Pell disbursements to student accounts with disbursements reported to COD. Person Responsible for Corrective Action Plan: Lori Larsh, Vice President for Business Services Anticipated Date of Completion: 07/31/2026

View Audit 402736

Finding 1216228 (2024-007)

Material Weakness 2024

Barclay College

KS

Student Financial Aid Material Weakness Matching / Level of Effort / Earmarking

Need Analysis Planned Corrective Action: All scholarships will be marked as estimated financial assistance and an awarding check for need will be done accurately before final distribution. Person Responsible for Corrective Action Plan: Lori Larsh, Vice President for Business Services Anticipated Dat...

Need Analysis Planned Corrective Action: All scholarships will be marked as estimated financial assistance and an awarding check for need will be done accurately before final distribution. Person Responsible for Corrective Action Plan: Lori Larsh, Vice President for Business Services Anticipated Date of Completion: 07/31/2026

View Audit 402736

Finding 1216227 (2024-006)

Material Weakness 2024

Barclay College

KS

Student Financial Aid Reporting

Enrollment Reporting to NSLDS Planned Corrective Action: A system will be put into place to ensure that enrollment is reported in a timely and accurate manner. Additionally, the College will complete a series of spot checks of NSLDS enrollment statuses throughout the year. Person Responsible for Cor...

Enrollment Reporting to NSLDS Planned Corrective Action: A system will be put into place to ensure that enrollment is reported in a timely and accurate manner. Additionally, the College will complete a series of spot checks of NSLDS enrollment statuses throughout the year. Person Responsible for Corrective Action Plan: Lori Larsh, Vice President for Business Services Anticipated Date of Completion: 07/31/2026

View Audit 402736

Finding 1216225 (2024-005)

Material Weakness 2024

Barclay College

KS

Eligibility Student Financial Aid Material Weakness

Satisfactory Academic Progress Planned Corrective Action: The SAP policy will be reviewed or created as needed and a procedure will be implemented based on that policy. Person Responsible for Corrective Action Plan: Lori Larsh, Vice President for Business Services Anticipated Date of Completion: 07/...

Satisfactory Academic Progress Planned Corrective Action: The SAP policy will be reviewed or created as needed and a procedure will be implemented based on that policy. Person Responsible for Corrective Action Plan: Lori Larsh, Vice President for Business Services Anticipated Date of Completion: 07/31/2026

View Audit 402736

Finding 1216220 (2024-004)

Material Weakness 2024

Barclay College

KS

Student Financial Aid Material Weakness

Lack of Administrative Capability Planned Corrective Action: The financial aid officer will participate in training(s) specific to knowledge gaps. In addition, monthly entries will be made in the general ledger for financial aid activity and monthly balances will be reconciled between the general le...

Lack of Administrative Capability Planned Corrective Action: The financial aid officer will participate in training(s) specific to knowledge gaps. In addition, monthly entries will be made in the general ledger for financial aid activity and monthly balances will be reconciled between the general ledger and financial aid software. Person Responsible for Corrective Action Plan: Lori Larsh, Vice President for Business Services Anticipated Date of Completion: 07/31/2026

View Audit 402736

Finding 1214588 (2024-012)

Material Weakness 2024

Roxbury Community College

MA

Student Financial Aid

Finding number: 2024-012 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2024 Corrective Action Plan: The College experienced significant turnover during FY24. Procedures have been updated to ensure timely reporting...

Finding number: 2024-012 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2024 Corrective Action Plan: The College experienced significant turnover during FY24. Procedures have been updated to ensure timely reporting of enrollment changes to the National Student Loan Data System (NSLDS). Timeline for Implementation of Corrective Action Plan: Immediate Contact Person Amy Cavelier Registrar

View Audit 401247

Finding 1214587 (2024-011)

Material Weakness 2024

Roxbury Community College

MA

Student Financial Aid

Finding number: 2024-011 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2024 Corrective Action Plan: The College experienced significant turnover during FY24. Additional review procedures have been implemented to e...

Finding number: 2024-011 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2024 Corrective Action Plan: The College experienced significant turnover during FY24. Additional review procedures have been implemented to ensure the accuracy of the Return of Title IV [R2T4] calculations. Retraining of federal regulatory requirements has been provided to all staff. Timeline for Implementation of Corrective Action Plan: Immediate Contact Person Loriann Weiss Interim Director of Financial Aid

View Audit 401247

Finding 1214586 (2024-010)

Material Weakness 2024

Roxbury Community College

MA

Student Financial Aid

Finding number: 2024-010 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2024 Corrective Action Plan: The College experienced significant turnover during FY24. The College has implemented standardized procedures for...

Finding number: 2024-010 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2024 Corrective Action Plan: The College experienced significant turnover during FY24. The College has implemented standardized procedures for Return of Title IV calculations, including required documentation and supervisory review. A tracking system is used to ensure timely return of funds and proper documentation retention. Retraining of federal regulatory requirements has been provided to all staff. Timeline for Implementation of Corrective Action Plan: Immediate Contact Person Loriann Weiss Interim Director of Financial Aid

View Audit 401247

Finding 1214584 (2024-008)

Material Weakness 2024

Roxbury Community College

MA

Student Financial Aid

Finding number: 2024-008 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2024 Corrective Action Plan: The College experienced significant turnover during FY24. Procedures have been updated to ensure timely and accur...

Finding number: 2024-008 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2024 Corrective Action Plan: The College experienced significant turnover during FY24. Procedures have been updated to ensure timely and accurate reporting of disbursements to the Common Origination and Disbursement (COD) system. Timeline for Implementation of Corrective Action Plan: Immediate Contact Person Loriann Weiss Interim Director of Financial Aid

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Finding 1214583 (2024-007)

Material Weakness 2024

Roxbury Community College

MA

Student Financial Aid

Finding number: 2024-007 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2024 Corrective Action Plan: The College experienced significant turnover during FY24. The College has implemented enhanced review procedures ...

Finding number: 2024-007 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster Assistance Listing #: 84.063 Award year: 2024 Corrective Action Plan: The College experienced significant turnover during FY24. The College has implemented enhanced review procedures for Pell Grant calculations, including system-based validation and secondary review prior to disbursement. Retraining of federal regulatory requirements has been provided to all staff. Timeline for Implementation of Corrective Action Plan: Immediate Contact Person Loriann Weiss Interim Director of Financial Aid

View Audit 401247

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